Animal By-Products not for human consumption

Mel Herzog

ABP Regulations

• Amended Regulations on imports of Animal By-Products not for human consumption came into force on 4th March 2011

• Regulation (EC) No 1069/2009 and Regulation (EU) 142/2011(as amended)

Covers imports of animal by-products NOT for human consumption only

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Used Cooking Oil (UCO)

• Changes came into force in January 2017 to Decision 2007/275 which now states when UCO which falls within the scope of point (g) of Article 2(2) of regulation (EC) No 1069/2009 consignments would need to be vet checked:

Catering waste unless it is destined for processing by pressure sterilisation or for processing by methods referred to in point (b) of the first subparagraph of Article 15(1) or for transformation into biogas or for composting;

• There are no harmonised import conditions in place for UCO at the present time.

• There are currently on going discussions at Commission level to set out harmonised conditions for UCO coming in for the purposes set out in point (g) of Article 2(2) of 1069/2009.

• An OVS note was issued on 21st December 2016 stating that the UK will continue to treat imports of UCO under Waste legislation and therefore will not be subject to vet checks until such time ABP rules are agreed

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LANOLIN AND INTERMEDIATE PRODUCTS

• Annex I point 35 of 142/2011 - As from 25th February 2015, the definition of an intermediate product included ABP intended for the manufacture of cosmetics.

• Products derived from wool grease (such as lanolin or lanolin derived products) which require NO further processing once imported and is intended for use in manufacturing cosmetics:

o as material in a manufacturing process or in the final production of a finished product;

o in validation or verification during a manufacturing process; or

o in quality control of a finished product;

• should be classed as an intermediate product and:

• Must come from an approved intermediate product establishment listed for that country

• Must come in with Chapter 20 declaration

• Must go to an approved ABP plant in the UK

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LANOLIN DERIVED PRODUCTS

• Commission Decision 2007/275 states that wool grease and fatty substances derived therefrom (including lanolin) are required to be vet checked.

• Various products can be derived from lanolin to produce other products such as lanolin alcohol.

• UK would still consider these products to be “a product derived therefrom” and they would still need to be vet checked under code 1505 UNLESS:

o The derived product has been processed to such an extent that the final product falls under a different CN code classification (i.e. such as a vitamin/ chemical etc)

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WOOL GREASE AND LANOLIN - FUTURE REQUIREMENTS

• We have been advised by the Commission that Wool grease and lanolin should comply with ABP rules on rendered fats under certain conditions. Advice from the Commission is as follows:

• As intermediate products intended for pharmaceutical or cosmetic industry (Model declaration Chapter 20 of Annex XIV to R142/2011);

• Rendered fats for the use in feed for farmed animals(Certificate Chapter 10(A) of Annex XIV to R142/2011);

• Rendered fats for the production of technical products (Certificate Chapter 10(B) of Annex XIV to R142/2011);

• Under national legislation for other uses

• Clarification still needed on what “other uses” means so clear advice can be given

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WOOL GREASE AND LANOLIN - FUTURE REQUIREMENTS cont:

• Clarification needed on acceptable processing methods.

• The IIN is being amended to take into account these new requirements.

• There will be a transitional period to assist importers during this period.

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FACTORY WASHED TREATED WOOL

• If wool has been factory-washed it can be classed as treated wool.

• IIN ABP 23B is available which lays down the current UK import requirements.

• One requirement is that treated wool must come from an approved ABP premises. The Commission has confirmed this.

• This is so there is assurance that an acceptable treatment has been carried out in the country of origin for the wool to be classed as treated wool.

• The IIN states that the approved establishment of origin must be stated on the commercial document and importers declaration, including the approval number of the establishment.

• If treated wool has not come from an approved premises then the consignment has not complied with EU requirements and should be dealt with accordingly.

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UNTREATED BLOOD PRODUCTS – FETAL BOVINE SERUM

• Chapter 4(C) certificate must be used.

• There are various options to describe the blood from which the blood product has been obtained.

• For fetal bovine serum this can include:

• Though not ideal this option can be used for bovines fit for human consumption at the time of slaughter.

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UNTREATED BLOOD PRODUCTS – WHEN TO CHANNEL

• In the case of certain animal by-products, following the veterinary checks provided for in Directive 97/78/EC, and in accordance with the conditions laid down in Article 8(4) of that Directive, those animal by-products must be transported directly from the BIP under Customs procedures to the registered establishment or plant of destination.

• OVS Note /2016/09 was issued on 28 April 2016 to give guidance on the procedures for OVS to follow when dealing with consignments that have to be channelled in accordance with Article 8(4).

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UNTREATED BLOOD PRODUCTS – WHEN TO CHANNEL CONT

• Not all blood products imported under their relevant health certificate needs channelling under Article 8(4).

• Not all animal species require the blood products to be channelled under Article 8(4).

• Channelling only applies to untreated blood products from certain animal species.

• Channelling only applies in certain disease situations in country of origin.

• Check the model certificate 4(C) – NOTE Part II (4) will tell you when you need to apply the channelling requirements

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UNTREATED BLOOD PRODUCTS – WHEN TO CHANNEL CONT

BLOOD PRODUCTS THAT DO NOT NEED CHANNELLING!

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BLOOD PRODUCTS – WHEN TO CHANNEL CONT

• Artiodactyla including crossbreeds

CHANNELLING WHERE VACCINATION AGAINST FMD IS OFFICIALLY CARRIED OUT FOR AT LEAST 12 MONTHS

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UNTREATED BLOOD PRODUCTS – WHEN TO CHANNEL CONT

• Perissodactyla including crossbreeds

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CHANNELLING WHERE VACCINATION AGAINST FMD IS OFFICIALLY CARRIED OUT FOR AT LEAST 12 MONTHS

UNTREATED BLOOD PRODUCTS – WHEN TO CHANNEL CONT

• Proboscidea, including crossbreeds

CHANNELLING WHERE VACCINATION AGAINST FMD IS OFFICIALLY CARRIED OUT FOR AT LEAST 12 MONTHS

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UNTREATED BLOOD PRODUCTS – WHEN TO CHANNEL CONT

• WILL NOT NEED CHANNELLING IF:

• From a third country or region of origin where no case of vesicular stomatitis and bluetongue (including the presence of seropositive animals) has been recorded for a period of at least 12 months and vaccination has not been carried out against those diseases for a period of at least 12 months in the susceptible species;

ANIMALS OTHER THAN SUIDAE AND TAYASSUIDAE

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UNTREATED BLOOD PRODUCTS – WHEN TO CHANNEL CONT

IN THE CASE OF SUIDAE AND TAYASSUIDAE ANIMALS

• BLOOD PRODUCTS WILL NOT NEED CHANNELLING IF:

• From a third country or region of origin where no case of swine vesicular disease, classical swine fever and African swine fever has been recorded for a period of at least 12 months, vaccination has not been carried out against those diseases for a period of at least 12 months and

• From a country or region of origin where no case of vesicular stomatitis (including the presence of seropositive animals) has been recorded for a period of 12 months and vaccination has not been carried out against this disease for a period of at least 12 months in the susceptible species.

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CUTTLEFISH BONES

• Changes came into force in January 2017 to Decision 2007/275 which now states that only cuttlefish bones containing soft tissue and flesh as referred to in point (k)(i) of Article 10 of Regulation (EC) No 1069/2009 need to be vet checked.

• Dried cuttlefish bones which have been cleaned and contain no soft tissue or flesh no longer need to be vet checked

• A General authorisation is being created to cover these types of import which will require commercial documentation

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IIN ABP 26 vs IIN ABP 43

• IIN ABP 26 applies to certain ABP products listed in the IIN which is intended for :

• food for wild birds;

• food for pet fish only;

• food for farmed fur animals

• The products are DEEP FROZEN OR DRIED ONLY

• Examples are:

o Dried whole mealworms

o Dried crickets

o Frozen krill/ blood worms

FOR FEED FOR ANIMALS OTHER THAN FARMED ANIMALS

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IIN ABP 26 vs IIN ABP 43 cont

• IIN ABP 43 applies:

• When it is a mix of processed ABP products which includes aquatic animals and terrestrial invertebrates ABP (i.e. contains krill/ cricket meal)

• The product cannot comply with the processed pet food requirements as premises of origin is not ABP approved.

• The processed product is intended for aquatic vertebrates (e.g. cold water and tropical fish) and invertebrates (e.g. coral/ starfish) , reptiles and amphibians.

• The final product has undergone a processing method.

• Examples are:

o Pre-packed feed for amphibians

o Specialist feeds of tropical aquarium animals such as coral/ starfish.

FOR FEED FOR ANIMALS OTHER THAN FARMED ANIMALS

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Thank you for listening

Any questions?

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